Iceberg Digital understands that your privacy is important
to you and that you care about how your information is used and shared online. We
respect and value the privacy of everyone who visits Our Site and will only
collect and use information in ways that are useful to you and in a manner
consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us
in relation to your use of Our Site. Please read this Privacy Policy carefully
and ensure that you understand it.Your acceptance of Our Privacy Policy is
deemed to occur upon your first use of Our Site OR You will be required to read
and accept this Privacy Policy when signing up for an Account. If you do
not accept and agree with this Privacy Policy, you must stop using Our Site
immediately.

1.Definitions and Interpretation

In this Policy the following terms shall have the following
meanings:

“Account”

means an
account required to access and/or use certain areas and features of Our Site;

“Cookie”

means a small
text file placed on your computer or device by Our Site when you visit
certain parts of Our Site and/or when you use certain features of Our Site. Details
of the Cookies used by Our Site are set out in section 12, below;

“Our Site”

means this website,
www.iceberg-digital.co.uk;

“UK and EU
Cookie Law”

means the
relevant parts of the Privacy and Electronic Communications (EC Directive)
Regulations 2003 as amended in 2004, 2011 and 2015; and

2.2Our data protection officer is Yusuf Tokgoz who can be contacted
at Yusuf@iceberg-digital.co.uk

3.Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. It does
not extend to any websites that are linked to from Our Site (whether We provide
those links or whether they are shared by other users). We have no control over
how your data is collected, stored or used by other websites and We advise you
to check the privacy policies of any such websites before providing any data to
them.

4.What Data Do We Collect?

Some data will be collected automatically by Our Site [(for
further details, please see section 12 on Our use of Cookies [and Our Cookie
Policy Insert Link])], other data will only be collected if you voluntarily
submit it and consent to Us using it for the purposes set out in section 5, for
example, when signing up for an Account. Depending upon your use of Our Site,
We may collect some or all of the following data:

4.1Name

4.2date of birth

4.3gender

4.4business/company name

4.5job title

4.6profession

4.7contact information such as email addresses and telephone numbers

4.8demographic information such as post code, preferences and
interests

4.9financial information such as credit / debit card numbers

4.10IP address (automatically collected)

4.11web browser type and version (automatically collected)

4.12operating system (automatically collected)

4.13a list of URLs starting with a referring site, your activity on Our
Site, and the site you exit to (automatically collected)

5.2We use your data to provide the best possible products and
services to you. This includes:

5.2.1Providing and managing your Account

5.2.2Providing and managing your access to Our Site

5.2.3Personalising and tailoring your experience on Our Site

5.2.4Supplying Our products and services to you

5.2.5Personalising and tailoring Our products and services for you

5.2.6Responding to communications from you

5.2.7Supplying you with email Insert Type of Email e.g. newsletters,
alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any
time by visiting preference centre

5.2.8Market research

5.2.9Analysing your use of Our Site to enable Us to continually improve
Our Site and your user experience;]

5.2.10Add further uses as required.

5.3In some cases, the collection of data may be a statutory or
contractual requirement, and We will be limited in the [products and] services
We can provide you without your consent for Us to be able to use such data.

5.4With your permission and/or where permitted by law, We may also
use your data for marketing purposes which may include contacting you by emailAND/OR telephone AND/OR text message AND/OR post with information, news
and offers on Our products AND/OR services. We will not, however, send
you any unsolicited marketing or spam and will take all reasonable steps to
ensure that We fully protect your rights and comply with Our obligations under
the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations
2003, as amended in 2004, 2011 and 2015.

5.5Under GDPR we will ensure that your personal data is processed
lawfully, fairly, and transparently, without adversely affecting your rights.
We will only process your personal data if at least one of the following basis
applies:

a)you have given consent to the processing of your personal data for
one or more specific purposes;

b)processing is necessary for the performance of a contract to which
you are a party or in order to take steps at the request of you prior to
entering into a contract;

c)processing is necessary for compliance with a legal obligation to
which we are subject;

d)processing is necessary to protect the vital interests of you or
of another natural person;

e)processing is necessary for the performance of a task carried out in
the public interest or in the exercise of official authority vested in the
controller; and/or

f)processing is necessary for the purposes of the legitimate
interests pursued by us or by a third party, except where such interests are
overridden by the fundamental rights and freedoms of the data subject which
require protection of personal data, in particular where the data subject is a
child.

6.How and Where Do We Store Your Data?

6.1We only keep your data for as long as We need to in order to use
it as described above in section 5, and/or for as long as We have your
permission to keep it. Your data will be deleted if we no longer need it in
accordance with the terms of our Data Retention Policy.

6.2Your data will only be stored within the European Economic Area
(“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and
Liechtenstein).

6.3Data security is of great importance to Us, and to protect your
data We have put in place suitable physical, electronic and managerial
procedures to safeguard and secure data collected through Our Site.

6.4Steps We take to secure and protect your data include:

6.4.1Firewall

6.4.2IP Limited Access

6.4.3Security Check on all personel have access to data

6.4.4Email Encryption

6.4.5Regular Backups

6.5Notwithstanding the security measures that We take, it is
important to remember that the transmission of data via the internet may not be
completely secure and that you are advised to take suitable precautions when
transmitting to Us data via the internet.

7.Do We Share Your Data?

7.1We may contract with third parties to supply products and services
to you on Our behalf. These may include payment processing, delivery of goods,
search engine facilities, advertising and marketing. In some cases, the third
parties may require access to some or all of your data. Where any of your data
is required for such a purpose, We will take all reasonable steps to ensure
that your data will be handled safely, securely, and in accordance with your
rights, Our obligations, and the obligations of the third party under the law.

7.2We may compile statistics about the use of Our Site including data
on traffic, usage patterns, user numbers, sales and other information. All such
data will be anonymised and will not include any personally identifying
information. We may from time to time share such data with third parties such
as prospective investors, affiliates, partners and advertisers. Data will only
be shared and used within the bounds of the law.

7.3In certain circumstances We may be legally required to share
certain data held by Us, which may include your personal information, for
example, where We are involved in legal proceedings, where We are complying
with the requirements of legislation, a court order, or a governmental
authority. We do not require any further consent from you in order to share
your data in such circumstances and will comply as required with any legally
binding request that is made of Us.

8.What Happens If Our Business Changes Hands?

8.1We may, from time to time, expand or reduce Our business and this
may involve the sale and/or the transfer of control of all or part of Our
business. Data provided by users will, where it is relevant to any part of Our business
so transferred, be transferred along with that part and the new owner or newly
controlling party will, under the terms of this Privacy Policy, be permitted to
use the data for the purposes for which it was originally collected by Us.

8.2In the event that any of your data is to be transferred in such a
manner, you will be contacted in advance and informed of the changes. When
contacted you will be given the choice to have your data deleted or withheld
from the new owner or controller.

9.How Can You Control Your Data?

9.1When you submit information via Our Site, you may be given options
to restrict Our use of your data. We aim to give you strong controls on Our use
of your data (including the ability to opt-out of receiving emails from Us which
you may do by unsubscribing using the links provided in Our emailsand
at the point of providing your details AND/OR by managing your Account).

9.2You may also wish to sign up to one or more of the preference services
operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate
Telephone Preference Service (“the CTPS”), and the Mailing Preference Service
(“the MPS”). These may help to prevent you receiving unsolicited marketing. Please
note, however, that these services will not prevent you from receiving
marketing communications that you have consented to receiving.

10.Your Right to Withhold Information and Your Right to Withdraw
Information After You Have Given it

10.1You may access certain areas of Our Site without providing
any data at all. However, to use all features and functions available on Our
Site you may be required to submit or allow for the collection of certain data.

10.2You may restrict your internet browser’s use of Cookies. For more
information, see section 12

10.3You may withdraw your consent for Us to use your personal data as
set out in section in 5 at any time by contacting Us using the details set out
in section 15, and We will delete Your data from Our systems. However, you
acknowledge this may limit Our ability to provide the best possible products
and services to you.

11.How Can You Access Your Data?

You have the legal right to ask for a copy of any of your personal
data held by Us (where such data is held). Please contact Us for more details
at Yusuf@iceberg-digital.co.uk or using the contact details below in
section 14.

12.What Cookies Do We Use and What For?

12.1Our Site may place and access certain first party Cookies on your
computer or device. First party Cookies are those placed directly by Us and are
used only by Us. We use Cookies to facilitate and improve your experience of
Our Site and to provide and improve Our products and services. For more
details, please refer to section 5, above, and to section 12.6 below. We have carefully
chosen these Cookies and have taken steps to ensure that your privacy is
protected and respected at all times.

12.2By using Our Site you may also receive certain third party Cookies
on your computer or device. Third party Cookies are those placed by websites,
services, and/or parties other than Us. We use third party Cookies on Our Site
for tracking and statistics.. For more details, please refer to section
5, above, and to section 12.6 below. These Cookies are not integral to the functioning
of Our Site.

12.3All Cookies used by and on Our Site are used in accordance with
current English and EU Cookie Law.

12.4Before Cookies are placed on your computer or device [, subject
to section 12.5] AND/OR [section 12.8], you will be shown a popup message
requesting your consent to set those Cookies. By giving your consent to the
placing of Cookies you are enabling Us to provide the best possible experience
and service to you. You may, if you wish, deny consent to the placing of
Cookies; however certain features of Our Site may not function fully or as
intended. [Certain features of Our Site depend on Cookies to function. UK
and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies
are shown below in section 12.6. Your consent will not be sought to place these
Cookies. You may still block these Cookies by changing your internet browser’s
settings as detailed below in section 12.10, but please be aware that Our Site
may not work as intended if you do so. We have taken great care to ensure that
your privacy is not at risk by allowing them.]

12.5The following first party Cookies may be placed on your computer
or device:

Name of Cookie

Purpose

Strictly Necessary

Iceberg_random

tracking

yesy

12.6Our Site uses analytics services provided by Google. Website
analytics refers to a set of tools used to collect and analyse usage
statistics, enabling Us to better understand how people use Our Site. This, in
turn, enables Us to improve Our Site and the products and services
offered through it. You do not have to allow Us to use these Cookies, as
detailed below, however whilst Our use of them does not pose any risk to your
privacy or your safe use of Our Site, it does enable Us to continually improve Our
Site, making it a better and more useful experience for you.

12.7The analytics service(s) used by Our Site use(s) Cookies to gather
the required information. Certain of these Cookies may be placed immediately
when you first visit Our Site and it may not be possible for Us to obtain your
prior consent. You may remove these Cookies and prevent future use of them by
following the steps set out below in section 12.10.

12.8The analytics service(s) used by Our Site use(s) the following
Cookies:

Name of Cookie

First / Third Party

Provider

Purpose

ga

third

google

analytics

12.9You can choose to enable or disable Cookies in your internet
browser. Most internet browsers also enable you to choose whether you wish to
disable all cookies or only third party cookies. By default, most internet
browsers accept Cookies but this can be changed. For further details, please
consult the help menu in your internet browser or the documentation that came
with your device.

12.10You can choose
to delete Cookies at any time however you may lose any information that enables
you to access Our Site more quickly and efficiently including, but not limited
to, login and personalisation settings.

12.11It is
recommended that you keep your internet browser and operating system up-to-date
and that you consult the help and guidance provided by the developer of your
internet browser and manufacturer of your computer or device if you are unsure
about adjusting your privacy settings.]

13.Summary of Your Rights under GDPR

Under the GDPR, you have:

13.1the right to request access to, deletion of or correction of, your
personal data held by Us;

To enforce any of the
foregoing rights or if you have any other questions about Our Site or this
Privacy Policy, please contact Us using the details set out in section 15
below.

14.Automated Decision-Making and Profiling

14.1 In the event that We use personal
data for the purposes of automated decision-making and those decisions have a
legal (or similarly significant effect) on You, You have the right to challenge
to such decisions under GDPR, requesting human intervention, expressing their
own point of view, and obtaining an explanation of the decision from Us.

14.2 The right described
in section 14.1 does not apply in the following circumstances:

a)The decision is necessary for the entry into, or performance of, a
contract between the You and Us;

b)The decision is authorised by law; or

c)You have given you explicit consent.

14.3Where We use your personal
data for profiling purposes, the following shall apply:

a)Clear information explaining the profiling will be provided,
including its significance and the likely consequences;

b)Appropriate mathematical or statistical procedures will be used;

c)Technical and organisational measures necessary to minimise the
risk of errors and to enable such errors to be easily corrected shall be
implemented; and

d)All personal data processed for profiling purposes shall be
secured in order to prevent discriminatory effects arising out of profiling.

15.Contacting Us

If you have any questions
about Our Site or this Privacy Policy, please contact Us by email at gdpr@iceberg-digital.co.uk by telephone on 01992 766637 or by post at Teulon Wing, Warlies Park
House, Horseshoe Hill, Waltham Abbey EN9 3SL. Please
ensure that your query is clear, particularly if it is a request for
information about the data We hold about you (as under section 11, above).

16.Changes to Our Privacy Policy

We may change this Privacy Policy as we may deem necessary from
time to time, or as may be required by law. Any changes will be immediately
posted on Our Site and you will be deemed to have accepted the terms of the
Privacy Policy on your first use of Our Site following the alterations. We
recommend that you check this page regularly to keep up-to-date.

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